Non-reporting of specified domestic transactions U/s 92BA with related parties

HDFC Bank Ltd. Vs ACIT (Bombay High Court)

Conclusion: Transaction of purchase of loan from HDFC ltd. would not cover within the meaning of Specified Domestic Transactions (SDTs) as the shareholding of HDFC Ltd. of 16.39% could not be clubbed with the shareholding of the HDFC Investments Ltd. of 6.25% to cross the threshold limit of substantial interest of 20%. Also, payment by assessee to HBL Global for rendering services would not fall under SDT as assessee was not directly beneficial owner of the s

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